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HomeMy WebLinkAbout04-5548 -... Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Frank R. Slusser, Jr" v, Defendant CIVIL ACTION -*,A W NO, 0'/ - S'C4tP CIVIL TERM IN DIVORCE Kimberly S, Slusser, You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, , Cumberland County Bar Association 32 South Bedford Street Carlisle, PAl 7013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the Court, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Frank R. Slusser, Jr., v, Defendant CIVIL ACTION - LA W NO, oL/ - G'SV l> CIVIL TERM IN DIVORCE Kimberly S. Slusser, COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, Plaintiff is Frank R. Slusser, Jr., an adult individual, who resides at 825 Opossum Lake Road, Carlisle, Cumberland County, Pennsylvania 17013, 2, Defendant is Kimberly S, Slusser, an adult individual. Her address is unknown, She is employed at Chapel Pointe at Carlisle, 770 S, Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 3, Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4, Plaintiff and Defendant were married on May 29, 1999 in Carlisle, Cumberland County, Pennsylvania, 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction, 6, The marriage is irretrievably broken, 7, Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling, 8. Plaintiff requests the Court to enter a Decree in Divorce, WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE I J _ r;' .L0,--1 Date: l ( ~ Mark F, Bayley, Esquire 155 S, Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court J.D. # 87663 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S. S4904, relating to unsworn falsification to authorities, Date: /~<1/d/ f~l!~ ~ 1fi tN ~ ~ () -0 toO f "'9. ......... ~ ~ ~ ~ ~ () ~: ~-.. eJtu f-i~~ r [ ! -;? '.);' I t;!.:',. r~~ I<'-~" ~?; (-) ~.~~ Z ~ ,.." <:::::> c::::J ..;::- Z c::> ....::: I w o .." -4 ffifQ C\ ~.? e :c~ -u () _,- :J::: -:;. 0 -"'-m 8 ):;>- ::0 -< Cd N U1 Frank R. Slusser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Kimberly S. Slusser, Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE AFFIDAVIT 01= GQ~SENT 1. A Complaint in Divorce under S3301(c) of the Divorce Code was filed on November 3,2004. 2. The marriage of Plaintiff and Defendant IS irretrievably broken and ninety (90) days have elapsed from the date of the tiling of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. s4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 3 h /:;?()oS' Date /'1 ~/ c'/. j .;E~:J; .ffiPfL/ .4" _;l~<" Frank R. Slusser y ...4'2>-' "" :;;0:., ?;":, J"'" d:) 1:< ~ Frank R. Slusser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Kimberly S. Slusser, Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (9 OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT i (jNDERSTAi\jC THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 34904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. '3/3/;;10(\:5 Date . fi ./' ./ J%/c4/~: / ... . / ;/Uc . Frank R. Slusser ~/ ....-4 "\... C. >\ ....,;,~ p: L;".' Frank R. Slusser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Kimberly S. Slusser, Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE AFr!DJI..\!!T OF CONSP.iT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on November 3, 2004. 2. The marriage of Plaintiff and Defendant is irretril3vably broken and ninety (90) days have elapsed from the date of the filing of the CQmplaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C,S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 7/dw/D5 Date / ~QIl~ ,f. _\'v U()[)Qf2 Kimberly S, SI ser S2 \. ~~ r--" = = cJ' ~c:: G") - ~ :?- '>, pir,,:c:. :(':'j~.i ~:.~\() .-,-' r: ..-~C) )~\n'~ ~: ~b .-< ~~. - - .r:- a:> - Frank R Slusser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Kimberly S. Slusser, Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 ~ OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, '7/;)(olTJ5 Date' I ~t~ J. ,1~liL1()OIi Kimberly 8. Slu r o S ,}., C:;.., 'iJ' ~~- t;) \ .- \ , Q "'~ -::? -(. <<"'Ie., ~,~\,C) -"'<<J \'::\\ -::::.", lC!. ~,'- \ " ' .); ~;;;J_ -::.- -' .' ~ c'J Frank R Slusser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Kimberly S. Slusser, Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on November 3, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3, I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. <6/11105 Date p~L~ Frank R Siusser oJ' /" .-- g ~ Sf, ~,. '6> ~~ ~tT:l ~ tJ;:C: c:;;') s:.- :,: ?6~ 2':, - SQ~:':- N 0 t;2.C -~-r, -0 .-;1-...-(" ~. . C2-"'" Z,-'J :;:; zC> -$'.0 .-f<\ c::: ~ S z:. .", ~ (,1\ '?:l N 'i Frank R. Slusser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Kimberly S. Slusser, Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301~) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice, 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, ~/;//os Date ~p4/-. rank R. Slusser (') ~ ~ = c = ~ en -.,..,....', "'" ~:n Q:\[~: c:: "'--e" G? ..",Hi ;:~c 5.Q ~-r:; N ~6 r ~--. -0 -1: -'$, C' :!J 210- ;:];; 9-~ -~C) 'J>c: Y? ~ ~ Ul ~ N -< Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Frank R. Slusser, Jr., v. Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE Kimberly S. Slusser, CERTIFICATE OF SERVICE . Complete __1, 2, and 3, Also complete _em 4 if Restridled Delivery i. desired. . Print your name and address on the reverse so that we can return the card to you, . Attach this card to the back of the mailpiece; or on the front ij space pennit., 1. Article Addressed to: . C C J6-m~ 0_ ~ 6/.,f 6;TU..,o YlIM./1VJ Dr. fY11 -VI< +0 &tuAJ J .' ~o ~, . - 6e. c;;;q.:s rO' ~, r/YY:: 2. AitlCleNumber ~ (TnInefer from ~1iIbeI) I PS Fonn 381 1. February 2004 7004 1350 0003 7142 5031 DomeetIc Return Receipt 102595-Q2-M-15040 Exhibit "A" ~ -T) (0 rnrn '-7':J.:) zr mE ?b <: ?:C) ~u ;p' c: ~ r--> = ,,,", (:-J"\ E:. en - o -n 1..,., P'F: -O}l4 ...::1....... ?'") ~ ~-J~fj '~ ~1J ,lo ;'c').n"1. ~:; ~2. 0' -r:J: ~ ~"",. (~.? ~ u:> - FTank R. Slusser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Defendant CIVIL ACTION - LAW NO. 04-5548 CIVIL TERM IN DIVORCE Kimberly S. Slusser, PRAECIPE TO TRANSMIT RECOIRD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: L Grounds for divoTce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: November 8, 2004 was served on Defendant by First Class Mail, Certified, and Retum Receipt Requested and signed fOT on November 12,2004. (attached as Exhibit "A") 3. Date of execution of the affidavit of consent required by ~ 3301(c) or The Divorce ~... Code: by the Plaintiff August II, 2005; by the Defendant July 26, 2005. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: on August 12,2005; Date Defendant's WaiveT of Notice in ~3301(c) Divorce was filed with the Prothonotary: on August 1,2005; a copy of which is attached. . /I /' Date: August 16, 2005 L~ Mark F, Bayley, Esquire 155 S. Hanov,er Street Carlisle, PA 17013 717) 241-6070 Supreme Court LD. # 87663 Attomey for Plaintiff 2 s -atr p;)n, ~-:-". zrc (fl,<-:, / ,: 2.-L~ - ~(~ "'!~c, J>c:: ~ 1:5 Q gi\ l ~:!l ~ ~t ~ 2~ o "" "" ,. ~ ~ '-< .0 ,,' . , . . " . . . " . . . . . . . . . . . . . . . . . . . . . . . . . " . . , . . , . . . . , , . " " . " " . . . . '. . . . :+i:+;;f.;f.:I; . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUN1~ STATE OF PEN NA. Frank R. Slusser, Jr. No. 5548 04 Plaintiff VERSUS Kimberly S. Slusser Defendant DECREE IN DIVORCE AND NOW, a".....~ / :z-t" , :z.oos', IT IS ORDERED AND DECREED THAT Frank R. Slusser, Jr. . PLAINTIFF, AND Kimberly S. Slusser , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Nnn~ By THE COURT: .1 -1 . ;4 Jk. J. a . .4 < ~ PROTHONOTARY . . . . . . . . . . . .. . " . " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " " " " " . . " . . . . . . . . . . . , , , .. .;fir ~ ~ PJY}j., y:J'Q2'g, f4 r ~ ~ hw.rv Xl-or) '., .". .~~.... ... ';.0 -" .